Policy Statements | Financial Regulatory Updates

May 28th 2026

PS15/26 – Pillar 2A review – Phase 1

Policy statement 15/26

AI Analysis

PS15/26 sets out the PRA’s final Phase 1 reforms to **Pillar 2A capital methodologies and reporting**, aligned with the UK’s Basel 3.1 implementation and intended to modernise how risks beyond Pillar 1 are captured. It introduces revised approaches and expectations across credit, operational, pension obligation, market and counterparty credit risk, plus substantial updates to ICAAP/SREP guidance and Pillar 2 reporting for both mainstream firms and SDDTs.

What Changed

- The PRA finalises amendments to the Reporting Pillar 2 Part of the PRA Rulebook, including updated Pillar 2 data items (FSA072–FSA076 and FSA081) and an updated Pillar 2 reporting schedule, with...
The PRA issues an updated Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital, providing revised methodologies across credit, operational, pension obligation, market...
The PRA issues an updated SoP 5/25 – The PRA’s methodologies for setting Pillar 2 capital for Small Domestic Deposit Takers (SDDTs), tailoring Pillar 2A approaches and expectations for SDDTs.
The PRA updates Supervisory Statement (SS) 31/15 – ICAAP and SREP, clarifying expectations on how firms should assess, document and justify Pillar 2A capital in ICAAPs, including how to reflect...
The PRA updates SS 4/25 – ICAAP and SREP for SDDTs, setting proportionate ICAAP expectations and aligning SDDT guidance with the revised Pillar 2A framework.

Suggested Considerations

Map your firm’s current Pillar 2A capital framework against the updated SoP 5/15 and, where applicable, SoP 5/25 to identify methodology changes across credit, operational, pension, market and counterparty credit risk.
Update ICAAP methodologies, models and documentation to reflect revised PRA expectations, including new or enhanced use of credit risk and operational risk scenarios and any updated calibration standards.
Review and, where necessary, redesign ICAAP governance (board oversight, senior management ownership, model risk and validation frameworks) to ensure that new scenario‑driven and systematic Pillar 2A methodologies are subject to appropriate challenge and approval.
For firms with material sovereign, central bank, regional government or unconditionally cancellable retail exposures, implement the new systematic Pillar 2A credit risk methodologies and assess the impact on capital requirements and risk‑weighted exposure allocation.
For firms with significant operational risk, enhance scenario analysis frameworks to capture low‑frequency, high‑severity loss events at the PRA’s expected soundness level, and embed these outputs into ICAAP capital quantification.

Key Dates

22 May 2025

– PRA published CP12/25 launching Phase 1 of the Pillar 2A review and consulting on revised methodologies and reporting

05 September 2025

– Consultation period for CP12/25 closed, with industry feedback informing PS15/26

02 March 2026

– Changes relating to pension obligation risk and market/counterparty credit risk methodologies and associated reporting expectations take effect

01 January 2027

– Basel 3.1 standards are implemented in the UK and the retirement of the refined Pillar 2A methodology takes effect; Phase 1 Pillar 2A changes for credit and operational risk are aligned to this Basel 3.1 implementation date

2027 (TBD)

– PRA plans to publish a further consultation paper (Phase 2) on an in‑depth review of individual Pillar 2A methodologies

Compliance Impact

The impact is high: the reforms change how Pillar 2A capital is calculated, justified and reported, with direct consequences for total capital requirements, ICAAP content and supervisory dialogue. Failure to implement the new methodologies and reporting expectations on time can lead to higher capital add‑ons, adverse SREP outcomes, supervisory remediation programmes and potential restrictions on distributions or business growth.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure

BankBroker Dealer

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🇬🇧 PRA Policy high

May 27th 2026

PS14/26 – CRR Definitions: restatement in PRA Rulebook

Policy statement 14/26

AI Analysis

PRA Policy Statement PS14/26 finalises the restatement of CRR definitions into the PRA Rulebook Glossary, with consequential amendments across other Rulebook Parts and updates to SS15/13 on groups. For compliance teams, the key issue is transition planning: the remaining CRR definitions are being moved out of the CRR framework, and firms must ensure their policies, capital documentation, systems, and references align with the PRA Rulebook versions before the repeal of CRR Articles 4–5 takes effect on 1 January 2027.

What Changed

- The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.

Suggested Considerations

Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.

Key Dates

July 2025

- HM Treasury published its Policy Update on applying the FSMA model of regulation to the UK CRR and proposed revoking the remaining CRR provisions while restating only necessary definitions

July 2025

- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook

January 2026

- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway

February 2026

- HM Treasury published a policy update confirming it would proceed largely as consulted on, with a change to the statutory definition of “securitisation” for consistency with PRA Basel 3.1 rules

February 2026

- The commencement statutory instrument revoking CRR Articles 4–5 was made, with effect from 1 January 2027

Compliance Impact

The compliance impact is moderate to high because this is a definitional restatement rather than a wholesale policy rewrite, but it affects the legal basis of many prudential references and could create misstatement risk if firms continue to rely on revoked CRR text after 1 January 2027. Non-compliance may lead to inaccurate capital, governance, or perimeter analysis, and could trigger supervisory findings where firms have not updated systems, documentation, or controls to the new Rulebook structure.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankAsset ManagerBroker Dealer

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🇬🇧 PRA Policy high

May 21st 2026

PS13/26 – Insurance third-country branches: policy implementation and other updates

Policy statement 13/26

AI Analysis

The PRA’s Policy Statement PS13/26 finalises the CP20/25 proposals on UK branches of third‑country (re)insurers, including raising the subsidiarisation threshold, embedding existing reporting and investment waivers into the Rulebook, and updating supervisory expectations on ORSA and resolution. Compliance teams at third‑country branches must now recalibrate threshold monitoring, overhaul reporting processes, and update governance and documentation to align with the revised Third Country Branches and Reporting Parts of the PRA Rulebook, updated SSs, and new Statements of Policy. ---

What Changed

- The PRA confirms an increase in the third‑country branch subsidiarisation threshold for liabilities covered by the Financial Services Compensation Scheme (FSCS) from £500 million to £600 million,...
Third‑country branch undertakings are now explicitly required to notify the PRA where projections show their FSCS‑covered liabilities may exceed the £600 million subsidiarisation threshold within a...
The PRA embeds in the Rulebook new quantitative thresholds for regulatory reporting, replacing the existing modification by consent (MbC) under Solvency II Reporting 2.2(1) for third‑country...
Under the new regime, only branches (excluding pure reinsurance branches) with at least £1 billion gross written premiums or £2 billion in branch provisions (based on the prior year’s annual...
The PRA discontinues quarterly reporting for certain non‑life claims templates and reinstates two annual reporting templates (IR.19.01.01 – non‑life insurance claims and IR.20.01.01 – development of...

Suggested Considerations

Assess current and projected FSCS‑covered UK branch liabilities against the new £600 million subsidiarisation threshold and implement or update a robust three‑year forecasting process to identify potential threshold breaches.
Update internal PRA notification procedures and early‑warning triggers so that the branch informs the PRA promptly if forecasts show FSCS‑covered liabilities could exceed the £600 million threshold within three years.
For branches approaching or exceeding the new threshold, initiate or refresh internal structural options analysis (branch vs subsidiary), including timeline, capital, governance, and operational impacts, and prepare for early engagement with the PRA on subsidiarisation expectations.
Map gross written premiums and branch provisions against the new £1 billion GWP and £2 billion provisions reporting thresholds and determine whether the branch will be subject to the full or reduced suite of third‑country branch regulatory reporting templates from 31 December 2026.
Redesign regulatory reporting processes, systems, and controls to align with the new reporting perimeter, including identifying which templates will be required, adjusting data capture, and ensuring capacity to produce reinstated templates IR.19.01.01 and IR.20.01.01 on an annual basis.

Key Dates

16 September 2025

– PRA publishes CP20/25, proposing changes to third‑country branch policy, including the higher subsidiarisation threshold and new reporting thresholds

16 December 2025

– Consultation period for CP20/25 closes; representations received from affected firms and stakeholders

Q1–Q2 2026

– PRA indicates that the increase in subsidiarisation threshold from £500 million to £600 million would take effect on publication of the relevant policy statement (PS13/26), with immediate relevance for threshold monitoring and branch vs subsidiary planning

31 December 2026

– Rulebook and policy changes (including amendments to the Third Country Branches and Reporting Parts, reinstatement of annual templates IR.19.01.01 and IR.20.01.01, embedded reporting thresholds, embedded pure reinsurance relief, updates to SS44/15, SS41/15, SS19/16, SoP6/24, SoP7/24, and SoP1/19, and disapplication/restatement of EIOPA Branch Guidelines) are scheduled to come into force

Compliance Impact

The impact is material for all UK branches of third‑country (re)insurers, particularly those near the new subsidiarisation and reporting thresholds, with consequences including potential forced subsidiarisation, expanded reporting burdens, or supervisory challenge if expectations on forecasting, ORSA, or resolution planning are not met. Non‑compliance could trigger PRA supervisory interventions, restrictions on business, and increased scrutiny during authorisation and ongoing supervision.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Reporting & Disclosure Authorisation & Licensing

InsuranceBank

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🇬🇧 FCA Policy medium

May 18th 2026

Our response to the Treasury’s policy statement on Consumer Credit Act reform

The Treasury has published its policy statement today on reform of the Consumer Credit Act 1974 (CCA). Reform of the CCA is an important step towards a more flexible regime that supports effective competition and innovation, while maintaining appropriate consumer protection both now and in the future. The proposals set out a framework that places greater emphasis on FCA rules and guidance rather than prescriptive requirements set out in legislation.We intend to consult on the key elements of ...

AI Analysis

HM Treasury has issued a policy statement on reform of the Consumer Credit Act 1974 (CCA), signalling a strategic shift from prescriptive, statute-based requirements towards an FCA rulebook-led regime for consumer credit. The FCA’s response confirms it will consult on moving key CCA elements into FCA rules and guidance, anchored in the Consumer Duty, which will materially reshape documentation, processes and conduct standards across the consumer credit lifecycle.

What Changed

- The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...

Suggested Considerations

Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.

Key Dates

Sectors:

General

Topics:

Senior Managers / Governance

All Firms

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